Privacy

Siamsoir and The Irish Dance Academy Privacy Policy [2018]

  1. Introduction

We are committed to respecting and protecting our customers’ privacy. This policy applies where we are acting as a data controller with respect to your personal data, in other words, where we determine the purposes and means of the processing of such personal data. It captures personal data entered across all channels: through our booking website or if you sign up to our newsletter on either company’s websites or when you email us directly and we want to contact you again.

We do NOT collect or store any of your financial details on this website.

We MAY collect “sensitive” personal data, such as your health, medical (such as allergies) or learning support requirements, if provided by you.

We do NOT collect any other “sensitive” personal details, such as your racial/ethnic origin, religious beliefs, political opinions or sexual life.

We MAY collect some personally-identifiable data from you, for example: we may need your name and email address if you sign up for our newsletter, or contact us. However, you can use most of this website without giving us any personally-identifiable data.

And we DO use Cookies.

Please read this policy carefully to understand our views and practices regarding your personal data and how we will treat it.

 

  1. How we use your personal data

In this section we outline how we may process your personal data. All personal data we process falls into one or more of the following categories:

  • Transaction data
  • Internal social data
  • Usage data
  • Communication data
  • Enquiry data
  • Digital marketing data

We may process your transaction data (“transaction data”). The transaction data may include information relating to your previous transactions, including TIDA Kit and classes / services booked. The transaction data may include your name, billing address, delivery address, telephone number, email address and purchase history. It may be processed for the purposes of supplying the purchased goods or services and keeping proper records of those transactions. The legal basis for this processing is the performance of a contract between you and us.

We may process information that you post for publication on our website or app, such as wall posts or product ratings and reviews (“internal social data“). This internal social data is public, and may be processed for the purposes of enabling interaction on the website between customers and staff. We may also use your posts or reviews in our marketing materials to help us tell other customers about our products and services. In instances where internal social data is stored in an unstructured format (such as free text reviews and wall posts) it is exempt from our data retention rules, however may be deleted upon request. The legal basis for processing internal social data is consent.

We may process data about your use of / reaction to our emails (“usage data“). The usage data may include your page views and website navigation paths, as well as information about the timing, frequency and pattern of your service use. The sources of the usage data are our analytics packages (including, but not limited to Google Analytics) and email service providers. This usage data may be processed for the purposes of analysing the use of the website. The legal basis for this processing is our legitimate interests, namely monitoring and improving our website and services.

We may process information that you provide to us for the purpose of subscribing to our direct marketing communications (“communication data“). The communication data may include your name, email address, phone number. This communication data may be processed for the purposes of contacting you with service notifications, such as relevant offers and messages. The legal basis for this processing is performance of a contract for service notifications and legitimate interests for direct marketing communications.

We may process information contained in any enquiry you submit to us regarding goods and/or services (“enquiry data“). This enquiry data may be processed for the purposes of providing clarification, resolving issues or marketing relevant goods and/or services to you. The legal basis for this processing is the performance of a contract between you and us and to ensure we are responding to your enquiry.

We may process information that you provide to us for the purpose of improving our digital marketing (“digital marketing data“). We may use digital marketing data in a number of different ways: either to advertise our products and services to you on third party websites such as Facebook, or to advertise our products and services to similar customers (lookalikes) on third party websites such as Facebook. We may also use digital marketing data to exclude you from seeing advertisements from third party websites such as Facebook. The digital marketing data may include your name, email address, phone number. The legal basis for this processing is our legitimate interests, namely providing better services and enhancing our customer base.

We may process any of your personal data identified in this policy where necessary for the establishment, exercise or defence of legal claims, whether in court proceedings or in an administrative or out-of-court procedure. The legal basis for this processing is our legitimate interests, namely the protection and assertion of our legal rights, your legal rights and the legal rights of others.

We may process any of your personal data identified in this policy where necessary for the purposes of obtaining or maintaining insurance coverage, managing risks, or obtaining professional advice. The legal basis for this processing is our legitimate interests, namely the proper protection of our business against risks.

Please do not supply any other person’s personal data to us, unless we prompt you to do so. If you do share your friends’ details with us, please ensure you have their authorisation.

  1. Providing your personal data to others

We do not, and will not, sell any of your personal data to any third party – including your name, address or email address. We want to earn and maintain your trust, and we believe this is absolutely essential in order do that.

Financial transactions relating to our website are handled by Paypal through both JotForm and BookWhen. We will share transaction data with our payment service providers only to the extent necessary for the purposes of processing your payments, refunding such payments and dealing with complaints and queries relating to such payments and refunds.

In addition to the specific disclosures of personal data set out in this Section 3, we may disclose your personal data with law enforcement and fraud prevention agencies, so we can help tackle fraud or where such disclosure is necessary for compliance with a legal obligation to which we are subject, in order to protect your vital interests or the vital interests of another natural person, or in connection with the establishment, exercise or defence of legal claims, whether in court proceedings or in an administrative out-of-court procedure.

  1. How long we retain your data

Personal data that we process for any purpose or purposes shall not be kept for longer than is necessary for that purpose or those purposes.

Whilst you are an active customer (which, for the avoidance of doubt, means you have purchased classes / services and TIDA Kit from us) we will retain your data for as long as needed to give you the best possible customer service. We will anonymise your personal data 7 years after your last transaction (sale or refund) provided you have not interacted with us for 2 years. For the purposes of this policy, an interaction is defined as an identifiable website session, or contacting us via email, in person on telephone either with you or if applicable child.

If you have submitted somebody else’s data (with their authorisation) as parent the same above applies.

In certain circumstances we may retain your personal data where such retention is necessary for compliance with a legal obligation to which we are subject, to resolve disputes and enforce our agreements.

  1. Your rights

You have a number of rights in respect to your personal data. We have summarised the rights that you have under data protection law. Some of the rights are complex, and not all of the details have been included in our summaries. Accordingly, you should read the relevant laws and guidance from the regulatory authorities for a full explanation of these rights.

  1. Right of access
    You have the right to confirmation as to whether or not we process your personal data and, where we do, access to the personal data, together with certain additional information. That additional information includes details of the purposes of the processing, the categories of personal data concerned and the recipients of the personal data. Providing the rights and freedoms of others are not affected, we will supply to you a copy of your personal data. The first copy will be provided free of charge. In order to fulfil this right we will ask for government registered ID to confirm your identity and, once this is received, will respond with the relevant information one calendar month from the date of your request.
  2. Right to rectification
    You have the right to have any inaccurate personal data about you rectified and, taking into account the purposes of the processing, to have any incomplete personal data about you completed.
  3. Right to erasure
    In certain circumstances you have the right to the erasure of your personal data without undue delay. However, there are exclusions of the right to erasure, such as where processing is necessary for exercising the right of freedom of expression and information, for compliance with a legal obligation, or for the establishment, exercise or defence of legal claims. If you have entered into a transaction with us, we will keep a record of your personal data for 7 years following the date of your last transaction with us. We will endeavor to respond to your request within one month, but if your request is complex or we receive a number of similar requests at the same time, it might take us longer, in which case we will inform you within one month of the receipt of the request and explain why we think an extension is necessary.
  4. Right to restriction on processing
    In some circumstances you have the right to restrict the processing of your personal data. Those circumstances are: (a) you contest the accuracy of the personal data, (b) processing is unlawful but you oppose erasure, (c) we no longer need the personal data for the purposes of our processing, but you require personal data for the establishment, exercise or defence of legal claims, and (d) you have objected to processing, pending the verification of that objection. Where processing has been restricted on this basis, we may continue to store your personal data. However, we will only otherwise process it: (a) with your consent, (b) for the establishment, exercise or defence of legal claims, (c) for the protection of the rights of another natural or legal person, or (d) for reasons of important public interest.
  5. Right to objection to processing
    You have the right to object to our processing of your personal data on grounds relating to your particular situation, but only to the extent that the legal basis for the processing is that the processing is necessary for: (a) the performance of a task carried out in the public interest or in the exercise of any official authority vested in us; or (b) the purposes of the legitimate interests pursued by us or by a third party. If you make such an objection, we will cease to process the personal information unless (a) we can demonstrate compelling legitimate grounds for the processing which override your interests, rights and freedoms, or (b) the processing is for the establishment, exercise or defence of legal claims.

You also have the right to object to our processing of your personal data for scientific or historical research purposes or statistical purposes on grounds relating to your particular situation, unless the processing is necessary for the performance of a task carried out for reasons of public interest.

  1. Right to data portability
    In certain circumstances, you have the right to receive your personal information in a structured, commonly used and machine-readable format and to transmit that information to another controller to enable it to use the data. The right to data portability applies (a) to personal data you have provided to us as data controller, (b) where the processing is based on the your consent or for the performance of a contract and (c) when processing is carried out by automated means. If you request this information, we will transmit the data directly to another controller, if this is technically feasible. We are, however, not required to adopt or maintain processing systems that are technically compatible with other controllers. Also, if the personal data concerns more than one individual, we must consider whether providing the information would prejudice the rights of other individuals.

If you exercise your right to data portability, we will endeavor to respond to your request within one month, but if your request is complex or we receive a number of similar requests at the same time, it might take us longer, in which case we will inform you within one month of the receipt of the request and explain why we think an extension is necessary.

  1. Right to stop marketing messages
    At any time you can amend your marketing preferences to reduce, remove or increase the amount we contact you with direct marketing communications. You can do this by unsubscribing at the bottom of each marketing email sent.
  2. Right to withdraw consent
    To the extent that the legal basis for our processing of your personal information is consent, you have the right to withdraw that consent at any time.
  3. Right to complain
    In the event that you wish to make a complaint about how we process your personal data, please contact us in the first instance at jennifer@siamsoir.co.uk and we will endeavour to deal with your request as soon as possible. If you consider that our processing of your personal information infringes data protection laws, you have a legal right to lodge a complaint with a supervisory authority responsible for data protection. You may do so in the EU member state of your habitual residence, your place of work or the place of the alleged infringement. Our supervisory authority is the Information Commissioner’s Office. You can contact them here: https://ico.org.uk

6. Cookies

We use cookies on our website. Cookies, sometimes called HTTP cookies, web cookies or browser cookies, are pieces of data stored by a website within a browser. That is to say the cookie created by a website is stored in the internet browser you are using such as Internet Explorer, Safari or Firefox.

When you open a website which has stored a cookie on to your computer the cookie is sent back to the website. This is a way of telling the website that you have been there before and it knows something about you. It may be to remember that you have logged in to the website before, to remember the things you have placed in your shopping cart, or to record the pages you visit.

As cookies can track what pages you visit and other information there has been some concern over privacy. The EU introduced legislation, which came into force in the UK in 2011, requiring owners of websites to information visitors about their use of cookies. Particular emphasis is given to the use of third party cookies which are not essential for the operation of the website. These include cookies placed by services such as Google Analytics, third party advertisers, and tracking cookies.

Our website is based upon the WordPress content management system and uses cookies to operate the website; in particular where visitors may be invited to log in to specific areas of the site.

We track the visitors to our website using  our own in house PiWik statistical reporting service. These place cookies in your browser to allow their operation. We use these services to see how people use the website, what areas are most popular and how people find out site. This data is anonymous and allows us to improve our website as we get to know what are visitors are interested in, what they looked for, and how long they visited.

We may, from time to time, use cookies to store information about your preferences, and so allow us to customise the site according to your individual interests and needs.

We may use cookies as a way to recognise you when you return to the website.

  1. Amendments

We may update this policy from time to time by publishing a new version on our website. You should check this page occasionally to ensure you are happy with any changes to this policy.

  1. Data Protection Officer

As a company we do not have a data protection officer, but our Director will be happy to address any concerns so do get in touch! jennifer@siamsoir.co.uk